The most significant change (and also the most controversial change based on public comments to the proposed change) is the definintion of what comprises an adequate incurred cost claim. Recall from yesterday that one of the propsed changes required contractors to submit adequate incurred cost claims, not simply incurred cost claims. The proposal revises FAR 52-216-7 to define the term "adequate".
In order to be considered adequate, an incurred cost proposal must include all of the following (unless otherwise specified by the cognizant Federal agency official).
- A summary of claimed indirect expense rates
- General and Administrative (G&A) expenses
- Overhead expenses
- Occupancy expenses
- Claimed allocation bases
- Facility Capital Cost of Money (FCCM) calculations
- Reconciliation of books of account and claimed direct costs
- Schedule of direct costs by contract/subcontract and indirect expense applied at claimed rates and the Government's participation in each indirect rate pool.
- Schedule of cumulative direct and indirect costs cliamed and billed
- Subcontract information
- Summary of hours and amounts on T&M/labor hour contracts
- Reconciliation of total payroll to total labor distribution
- Listing of decisions/agreements/approvals and description of accounting/organizational changes
- Certificate of final indirect costs
- Contract closing information for contracts completed during the fiscal year.
Many of you will recognize this list as coming from DCAA's electronic incurred cost excel model (ICE) or its paper version Information for Contractor's Phamphlet (DCAAP 7641.90).